For the Docket

Revisions to the Total Coliform Rule; Proposed Rule
Docket ID No. OW-2008-0878

Meeting with Representatives from the American Water Works Association (AWWA)

      October 28, 2010
 
In Attendance:  

	EPA  -   Pam Barr, Office of Ground Water and Drinking Water (OGWDW)
		Crystal Rodgers-Jenkins, OGWDW
		Sean Conley, OGWDW
		Tom Grubbs, OGWDW
		Julie Javier, OGWDW
		Karl Anderson, OGWDW
		Sandyha Parshionikar, OGWDW (by phone)
		Jennifer Best, OGWDW (by phone)

       AWWA  -  Alan Roberson
		Steve Via

Summary:  

AWWA requested the meeting to describe their comments on the proposed revisions to the Total Coliform Rule (TCR) and provide an opportunity for EPA to ask questions if necessary to better understand the comments.  Specifically, AWWA reviewed their comments on:

   * The process to review the TCR analytical methods
   * Concerns about where they believe that the proposed rule differs from the recommendations of the advisory committee as documented in their Agreement in Principle
   * State flexibility for determining compliance with the treatment technique requirements for assessment and corrective action
   * Guidance and training and possible stakeholder involvement in both
   * State concerns with the proposed rule
   * Repeat sampling locations
   * Invalidation of E. coli samples
   * The variance and exemption provisions relating to biofilm

AWWA did not submit any new comments.  EPA asked questions but did not provide any information about EPA positions regarding addressing comments received or possible final rule requirements.
